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#2014514 - 05/15/15 08:50 PM Rewards Card Disclosures
Matt_B Offline
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Matt_B
Joined: Sep 2011
Posts: 1,648
A CU, Where Regs Don't Apply
We're in the middle of redoing some of our brochures (tri-fold style), and a question was posed regarding the one for our rewards credit card. The brochure is also the application. When they initially designed the program, someone decided there should be T&Cs for the rewards program on the back and got some verbiage from the vendor on that.

It covers things like: points earned per dollar spent, the website to go to in order to see what points can earn, how thing will appear on your statement, that your account has to be open/in good standing to redeem points, the program can be terminated at any time, certain restrictions may apply, how long before points expire, and contact info, basically.

Marketing is now trying to figure out if this two page copy and paste from the disclosure that comes with the card is even necessary.

Based on my understanding of rewards programs, it's all contract law "stuff", not a regulation issue. So long as it's being disclosed along with the rest of the card disclosures, I don't see why it would need to be included up front. A simple statement directing someone to our website for more info, or even to the rewards site, sure, but not two full pages of duplicative junk.

Am I missing something?
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#2015048 - 05/19/15 08:01 PM Re: Rewards Card Disclosures Matt_B
NotALawyer Offline
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NotALawyer
Joined: Nov 2001
Posts: 455
I agree with what you're thinking in that it isn't needed. The one caveat is that significant terms/restrictions should be included in the brochure. Some banks have been hit with the UDAP (now UDAAP) stick for not including those.

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#2015073 - 05/19/15 09:02 PM Re: Rewards Card Disclosures Matt_B
Matt_B Offline
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Matt_B
Joined: Sep 2011
Posts: 1,648
A CU, Where Regs Don't Apply
Thanks for the thoughts. I'm thinking aside from points per $ and point expiration term, that we could just link to the site for more information and that might be enough.

We'll see!
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